Beruflich Dokumente
Kultur Dokumente
FILED
MAY - e 201#e UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
THOMASG. BR'TON EASTERN DTVISION
CIERK, U.S. DISTRICT COURT
v.
N. 18Cn s86
Violations: Title 18, United States
XAVIER ELIZONDO, Code, Sections 371,64t, and 1001(a)
also known as'X," and
DAVID SALGADO
JUDOIISIlEttY
HAEISTBATE JIESI COTT
COT]I{T ONE
(a) The Chicago Police Department ("CPD") was an agency of the City
of Chicago, a local government located in the Northern District of Illinois. The CPD
received in excess of $10,000 in federal funding during the period from April 1,2017 ,
officer. ELIZONDO held the position of sergeant and oversaw one of the CPD's Area
Central gang teams assigned to Chicago's 10th District. As a CPD officer, ELIZONDO
assigned to ELIZONDO's 10th District gang team. As a CPD officer, SALGADO was
(d) CPD officers could apply to State court judges for search warrants
that would authorize the officers to enter and search physical locations, such as a
home. A'U. Doe" search warrant was a particular type of search warrant that could
confidential informant. In order to obtain a "J. Doe" search warrant from a State
court judge, a CPD officer had to submit a search warrant application, including a
sworn complaint that contained truthful information that justified the search of a
particular location. In the sworn complaint, the CPD officer was required to detail
and the confidential informant was referred to as "J. Doe" to protect the confidential
informant's identity. The CPD officer was also required to bring the confidential
informant before the State court judge, so that the judge could observe and examine
(e) State law and CPD regulations required CPD officers to inventory
property obtained from searches, and maintain custody of all seized property pending
return of the property to the owner, or alternative judicial disposition of the property.
State law and CPD rules precluded CPD officers from converting property obtained
during searches to personal use, or using property obtained during searches to pay
confidential informants.
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XAVIER ELIZONDO,
also known as'X," and
DAVID SA].GADO,
defendants herein, did knowingly conspire with each other and with others known
and unknown to the Grand Jrry, to commit an offense against the United States, that
is, to embezzle, steal, obtain by fraud, and otherwise without lawful authority
knowingly convert to the use of any person other than the rightful owner and
intentionally misapply, property that was valued at $5,000 or more that was under
the care, custody, and control of the CPD, in violation of Title 18, United States Code,
Section 666(aX1)(A).
SALGADO agreed to steal and misapply property and evidence, such as United
SALGADO knowingly (i) submitted materially false "J. Doe" search warrant
applications to State court judges; and (ii) caused individuals posing as "J. Doe"
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fraudulently obtain search warrants that would enable the defendants to enter and
to seize property at various locations, and thereafter steal and otherwise misapply
the property.
criminal activity and acting as "J. Doe" confidential informants that they would
SALGADO gave property seized from various search locations, including but not
confidential informants in return for their information about illegal activity and their
SALGADO concealed their theft and conversion of property by, among other things,
falsifring police reports, including details therein about the amount of property, such
as United States currency, seized from various search locations and the disposition
of this property.
8.. It was further part of the conspiracy that defendants ELIZONDO and
concealed, and hid, the existence, purpose, and acts done in furtherance of the
conspiracy.
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following overt acts, among others, in the Northern District of Illinois, Eastern
Division:
told CS-1 that he would give CS-1 and Confidential Informant A a portion of any
property recovered inside the residence afber ELIZONDO and his CPD gang team
searched it.
(d) On or about December L9,2017, defendant SAIGADO prepared
SALGADO caused Confidential Informant A to appear before a State court judge and
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falsely pose as the source of inforrnation contained in the false "J. Doe" search
warrant application.
swore under oath to a State court judge that the information contained in the false
communicated on a cellphone with CS-1 while he, defendant SALGADO, and other
property.
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COTJI{T TWO
Eastern Division,
XAVIER ELIZONDO,
also known as'X," and
DAVID SALGADO,
defendants herein, embezzled, stole, purloined, and knowingly converted to their own
use money of the United States, namely, approximately $4,200 in United States
COI.]I{T THREE
incorporated here.
included allegations that ELIZONDO and SALGADO were embezzling, stealing and
converting to their use and to the use of others property obtained from various
January 29,20L8, SALGADO departed work afber his shift began and returned home
DAVID SALGADO,
defendant herein, did knowingly and willfully make a materially false, fictitious, and
government of the United States, when he stated that he did not remember whether
he had returned home on Januar;r 29,2018, after initially leaving home for his 5 p.m.
CPD shift.
A TRUE BILL:
FOREPERSON